NASW Statement on SSI Eligibility for Children with Disabilities

The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 contains Supplemental Security Income (SSI) provisions that addresses the manner in which children are assessed for disability determination. In particular, the Individual Functional Assessment (IFA) for children is eliminated. Children can qualify only if they have "a medically determinable physical or mental impairment which results in marked and severe functional limitations."

This more restrictive threshold requires that the Social Security Administration re-determine the eligibility of current SSI beneficiaries by August 22, 1997. There are currently approximately 1 million children now receiving SSI benefits. The children most likely to lose benefits are those suffering multiple impairments, none of which is severe enough to meet the more stringent disability criteria established by the law, but the combined effect of which is substantial. This includes children with mental retardation, tuberculosis, diabetes, organic mental disorders, autism, multiple sclerosis, cerebral palsy, epilepsy, brain injuries and burns. The Congressional Budget Office estimates that 267,000 children will lose SSI over the next 6 years due to the elimination of the IFA.

Another SSI provision in the welfare reform legislation removes references in the medical listing to "maladaptive behavior" in evaluating personal/behavioral functioning of children with medical impairments. CBO states that over the next six years, 48,000 children will lose access to benefits as a result of this change. Thus, by 2002, 315,000 low-income children who would have qualified under the previous law will be denied SSI--- or 22 percent of previously eligible children.

The Administration can address both the intent to narrow the eligibility for the program wile retaining eligibility for severely disabled children by carefully developing eligibility standards based on the best interests of the children.

NASW recommends that (1) the new SSI children’s disability criteria include a broad functional approach and that combinations of impairment should be permitted to equal severe disability; and (2) the SSA criteria be based upon eligibility standards applied to each child rather than arbitrary rules applied to a group to achieve a predetermined numerical goal.

November 21, 1996

For further information, contact Caren Kaplan at mailto:ckaplan.